Friday, January 27, 2012

Mystery of Airborne Combustible Dust Concentrations




So at what threshold should airborne concentrations of combustible dust trigger a concern for combustible dust related fires and explosions? Mention of industrial hygiene issues is reminiscent of the 2011 Foxconn catastrophic dust explosion in China, where initially workers complained of high levels of aluminum dust respiratory exposure during polishing operations.

Confusion still exists according to media accounts of the high airborne dust levels discovered in the WorkSafeBC inspections at the British Columbia, Canada facility a few weeks prior to Fridays catastrophic explosion. These high levels were for airborne concentrations in regards to respiratory exposure not combustible dust explosive concentration levels. Explosive airborne dust concentrations would require approximately 30,000 times more than the concentration found in the inspections depending on moisture content and particle size. For example, the highest airborne concentration was 5.9 milligrams/cubic meter, which was 2 times over the acceptable threshold of 2.5 milligrams/cubic meter, according to WorkSafeBC inspection reports released to the media.

To put this into perspective we must ask what exactly is 2.5 milligrams? Well if you put a pesky mosquito on a laboratory scale that would be your answer. Of course mosquitoes are not processed in sawmills, lumber is. But this does provide a general idea of 2.5 milligrams of mass. Alternately, using the mass of wooden toothpick provides better idea of how high suspended dust concentrations would be in one cubic meter of volume, such as the volume of a huge glass fish tank.

So here is the math. On an average, a wooden toothpick weighs approx. 100 milligrams on a laboratory scale. Now dissect the toothpick into 40 parts, which would equate to each of the forty toothpick parts weighing the same as a 2.5 milligram mosquito.

Now take three of those individual 2.5 milligram toothpick parts and grind them up to the consistency of sawdust. This would provide about total 7.5 milligrams of mass, a little over the 5.9 milligrams of the high airborne dust level that inspectors found in a cubic meter during the prior facility inspection.

So one must ask, is approx. 1/10 of wooden toothpick sawdust explosive in a cubic meter volume of air? The basis of a combustible dust explosive atmosphere is that the minimum explosive concentration (MEC) must be sufficient to have ignition while in suspension when combined with the fire triangle.Think of MEC analogous to the lower flammable/explosive level LFL/LEL of a flammable vapor or gas.

In contrast a minimum explosive concentration (MEC) of sawdust depending on moisture content and particle size is approximately 300 wooden toothpicks, weighing approximately 30 grams or 30 grams/cubic meter.Hope this helps obtaining insight in the difference between airborne respiratory hazards (milligrams) in contrast to airborne explosive concentrations (grams) of combustible dust. Of extreme importance is to ensure horizontal layers of dusts do not become airborne where a safe respiratory concentration can escalate rapidly into a minimum explosive concentration (MEC). Good housekeeping is key in this respect.

Combustible Dust Workshop: Managing a Complex Occupational Hazard




Wisconsin Combustible Dust Workshop in Milwaukee, Thursday February 23, 2012. Federation of Environmental Technologists, Inc. (FET), WI CHMM Chapter.




Chairman and WI CHMM Chapter President Mike McCoy

Combustible Dust Overview: Dr. George Gruetzmacher, WI State Laboratory of Hygiene


Regulatory Aspects of Combustible Dust and Potential Rulemaking: George Yoksas, OSHA

Combustible Dust – OSHA’s National Emphasis Program (NEP) Casts a Broad Net David McClurg, Esq., Petrie & Stocking, S.C.

Understanding and Interpreting Combustible Dust Analytical Data: Brian Kingsley, Chillworth Global

Combustible Dust Protection Systems: Dave Grandaw, Fenwal

Notable Combustible Dust Explosions and Lessons Learned: John Astad, Combustible Dust Policy Institute

Resources
WI CHMM Chapter
Federation of Environmental Technologists

Thursday, January 26, 2012

Full Report: Explosion of DeBruce Grain Elevator, Wichita, Kansas; June 8, 1998

Excellent overview on how a combustible dust explosion is investigated. Includes many educational pictures with comments in APPENDICE A Scientific basis for the analysis of the explosion

Grain Elevator Explosion Investigation Team (GEEIT), Vernon L. Grose, D.Sc., Editor
Report Placed in Final Electronic Format By David K. McDonnell of OSHA in Cooperation with GEEIT

Special thanks to Dr.Bill Kauffman, for sharing the DeBruce report. Viewers will find chapters absent from the initial OSHA web page regarding the DeBruce Grain Elevator Explosion - Report in the section below

Chapter 1, Chapter 2, Chapter 3, Chapter 8, Chapter 14, initial OSHA web page

Cover

https://docs.google.com/open?id=0Bw8dBi76LJibYjMwZjg5MDgtZDdkNC00YzM0LWE2NTItYmIwNWViOGJhY2Ez

Cover inside

https://docs.google.com/document/d/15JyKtxN5C8ztmkhp4GtgGnppwvRwlzBwmFAWuDdjF0Q/edit

Report Table of Contents

https://docs.google.com/document/d/1Q1tynPH2_SSqPJN6akZAl5f21-5-w1ON8zV3EoKP3sk/edit

List of Figures in the Report

https://docs.google.com/document/d/1jA6z5ayoMDRy2JfGXvFXIlRuXRojaP9xGbz_5dOs1HA/edit

Chap 4 DeBRUCE MANAGEMENT ROLE IN EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibZDM3ZGI0NTgtNjA5Yi00NTc1LTk2ZmEtNjczMGRmMjdhNjI1

Chap 5 DeBRUCE OPERATIONAL ROLE IN EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibZmYyYWU5NDMtMThkMy00ZjI0LTg0ZGQtZTI1NGMyODMyYWRh

Chap 6 ELEVATOR STATUS AT EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibMWRmMzUyYjEtNTAzMS00NzliLThmNTktZmMwN2EwMTdlMmYx

Chap 7 GRAIN ELEVATOR EXPLOSION FACTORS

https://docs.google.com/open?id=0Bw8dBi76LJibMjM4NTIzMjYtMGIwYy00N2Q3LThlOWUtMzk0NTAzYTE5MTlh

Chap 9 WITNESS TESTIMONY

https://docs.google.com/open?id=0Bw8dBi76LJibN2QwMDIxYzAtNjVlOC00OGRlLWEyMmUtYWIzNjQ3MmE4MzZm

Chap 10 TRENDS IN GRAIN HANDLING

https://docs.google.com/open?id=0Bw8dBi76LJibMGE5NDg3OWEtNTg1Yi00ODZiLTk5OWUtNDcyMDE3ZGE4MzYz

Chap 11 ECONOMICS OF GRAIN DUST

https://docs.google.com/open?id=0Bw8dBi76LJibZWNmZTI0NjEtZWQxYi00NmRiLWEwNmYtNGEwMTI0NTE2ZWYy

Chap 12 ROLE OF WORKERS COMPENSATION

https://docs.google.com/open?id=0Bw8dBi76LJibN2Q0ZmFiMGQtNDdiZS00Yzg5LTgwYzQtZDFlOWVlNjcyNzRj

Chap 13 INVESTIGATION LESSONS LEARNED

https://docs.google.com/open?id=0Bw8dBi76LJibMmZkMjc0MWItYjkzNi00N2Q5LWE0ODItZTBhZjMzOWYxNzFm

APPENDICE A Scientific basis for the analysis of the explosion

https://docs.google.com/open?id=0Bw8dBi76LJibMjBhMGE3ZWMtNDJlMi00MzFkLWEzNGEtZjAwN2E3Y2VjYjUx

APPENDICE B Industrial Maintenance, Inc. solicited proposals

https://docs.google.com/open?id=0Bw8dBi76LJibN2NkNGY0OWItNzMyNS00ZjZiLTgzYTgtMzE1YmNhZTZlMWQ4

Proposals

https://docs.google.com/open?id=0Bw8dBi76LJibOGZjYmJmM2YtYTRhOC00NTM5LWI0MzYtZTA0NmQ2YjMyZjQ5

APPLICABLE FEDERAL REGULATIONS

https://docs.google.com/open?id=0Bw8dBi76LJibNDBhNjRlMTAtYjU5OS00OTU5LWEwZTQtMGRkMjA1MGQzMGFj

REFERENCES

https://docs.google.com/open?id=0Bw8dBi76LJibOTU5NjQ1NzQtYTgxOS00NzAzLWI4MDAtZGMxOTNkMjUwM2U0

ACKNOWLEDGEMENTS

https://docs.google.com/open?id=0Bw8dBi76LJibZDVmY2M4MjItOTgwNi00MzE4LWFjOTctZDRhMjc2MGVhOWI1

GEEIT MEMBERSHIP

https://docs.google.com/open?id=0Bw8dBi76LJibMDY5MWJlOGUtYWQ1ZS00ZDkxLWI1ZTItMzRiZDM0ZDc1N2Nl

Friday, January 28, 2011

Global Incident Awareness Can Save Lives

Two strikingly similiar pictures, two different countries, yet the explosive effects in these storage tanks were basically the same in the liquor pulping recovery process. In both catastrophic incidents fatalities occurred at corrugated packaging manufacturing facilities. The incident in France happened this month and the other in Wisconsin back in 2008, which the Chemical Safety Board is currently investigating. As a result of the Wisconsin incident CSB issued a March 2010 Safety Bulletin on Hazards of Welding and other Hot Work.

Christian Bourdon, the contract worker from Saint-Aubin, France died unnecessarily in the hospital as a result of injuries sustained from the explosion while doing hot work on the storage tank. Don't know if Christian or others in the global workforce had a chance to read the educational CSB bulletin. Incident investigations determining root cause and safety bulletins are great if the information is being received by OHS professionals then passed on to the workforce. Yet it is difficult to understand why repeatable catastrophic incidents are occurring when information is abundant concerning the hazards. Providing examples of these two incidents is even harder to grasp since the manufacturing and storage process were the same.

It is unacceptable that life-saving information resides securely within national borders when occupational health and safety is a global concern. In contrast global financial markets send and receive data real-time. So is the value of the buck of more importance than human life?

Resources
Paper & Pulp Mill Process Magnetrol International

Monday, January 17, 2011

Legislators, More Regulation is the ComDust Cure

Why is it that legislators seem to think that passing more bills and regulations is the cure all? Problem with the combustible dust issue is that no one in Washington D.C. has all the facts and solely utilizing the Chemical Safety Board's Dust Hazard Study provides a false perception of the enormity and complexity of the issues both social and economical.

"Their bill would tell OSHA to issue - within 90 days - an interim standard. It would require better housekeeping, engineering controls, worker training and a written combustible-dust safety program."
Savannahnow.com-news article

For example, the CSB report states there were 281 ComDust incidents from 1980-2005, or an average of eleven incidents annually. In stark contrast, according to media accounts of ComDust related incidents since 2008 there have on an average 12 incidents a month. This would equate to approximately 4,000 ComDust incidents during the 1980-2005 timeframe.

Not understanding the depth of the issue is only part of the problem. For example FEMA/U.S. Fire Administration's, "National Fire Incident Reporting System 5.0 (NFIRS)" via local fire departments has failed to report and identify process situations, process conditions, and process materials regarding combustible dust related fires, precursors to catastrophic dust explosions.

If the local fire and explosions hazards can't be identified, then how can they be evaluated and controlled? Of course legislators at the national level seem to think legislation and regulation is the answer for a local/regional problem. That is the easy way out in attempting to solve a primarily fire life safety issue and secondarily an occupational safety issue.

The OSH ACT specifically states that to address workplace safety, issues of regulation, education, outreach, and research must be pursued. OSHA with its limited resources cannot do it all.

"by providing for research, information, education, and training in the field of occupational safety and health; and for other purposes."

What happened to NIOSH as the OSH ACT intended in getting involved with outreach/education regarding the combustible dust issue as it had done decades ago concerning coal mine dust explosions, prior to when the U.S Bureau of Mines (USBM) was transferred to NIOSH, Department of Energy (DOE), U.S. Geological Survey, and the Bureau of Land Management in 1995-97.

Let’s all grow up and stop singling out Imperial Sugar explosion as the problem. Currently Imperial Sugar is an industry leader in addressing ComDust fire and explosion hazards. What about the tens of thousands manufacturing facilities that have potential ComDust fire and explosion hazards? So now OSHA as Secretary of Labor states, "there's a new sheriff in town." So what we going to do, fine them all?

Outreach, training, research, and education through NIOSH and US Fire Administration are just a few examples in alternatives to more legislation and regulation. Question is, who has the vision in providing the leadership so all local, state, and federal agencies are working together in these tough economic times.

Resources -OSH Act

Saturday, January 15, 2011

Ten ComDust incidents per year...Say What?



At a recent combustible dust webinar last October, attendees to the educational event learned that about ten combustible dust incidents occurred annually from the early 1980s until 2005 in the U.S.A. This data was obtained from the Chemical Safety Board Dust Hazard Investigation that was completed in 2006, noting 281 ComDust incidents from 1980-2005.

Unfortunately, this is not reality in contrast to media reports that note over ten combustible dust incidents every month. Currently, OSHA is in the combustible dust rulemaking process utilizing this incomplete data from the CSB Dust Hazard Study. This presents a problem by not exposing the enormity and complexity of combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors.

The problem is exasperated by the current OSHA Combustible Dust National Emphasis Program (NEP) that further lessens the magnitude of combustible dust incidents by solely listing certain national industries (NAICS) that have a potential for combustible dust incidents and excluding thousands of other manufacturing plants that do have a history of ComDust incidents not listed in the ComDust NEP. For example, in 2008 over 50% of facilities that had ComDust incidents were not listed in the Appendices D-1 and D-2 of the NEP.

If your facility generates combustible dust it doesn't matter whether OSHA acknowledges the hazard our not in the ComDust NEP. Bottom-line, you have a potential fire and explosion hazard that can cause grave burn injuries, fatalities, and severe property damage. Get your dust tested now or at least conduct a thorough process hazard analysis; identifying, evaluating, and hopefully controlling the hazard.

To learn more about combustible dust hazards be sure to check out the excellent Chemical Processing. com webinar moderated by Traci Purdum, Senior Editor/Digital Media. Presenters included Dr Vahid Ebadat Ph.D/Chilworth Technology, Inc., John Dauber, sales manager/Camfil Farr APC, Bob Korn, Director of Sales for Explosion Protection Products/Fike Corporation, and Guy Colonna, Division Manager, managing the Industrial and Chemical Engineering department for the National Fire Protection Association.

Resources
Google Map Dec 2010-Jan 2011 Combustible dust related fires and explosions
Dust Gets it's Due- By Seán Ottewell, Editor at Large-Chemical Processing.com

Friday, January 14, 2011

Confined Structure Fires also Combustible Dust Related?

Just prior to the Christmas holiday a minor combustible dust related fire occurred in a dust collector at a Misc. Fabricated Metal Producing Manufacturing/NAICS 332999 facility in Wisconsin. These type of facilities are listed in Appendix D-2 of the OSHA ComDust NEP as Fabricated Metal Products, Not Elsewhere Classified with industries that may have Potential for Combustible Dust Explosions/Fires.

According to the news account:

The fire was extinguished and contained to the dust collector bag house. There was no fire extension into manufacturing plant.
WQOW.Com

The incident begs the question was this a confined structure fire? Where as in similiar small fire incidents that are limited in scope, are confined to noncombustible containers, rarely result in serious injury or large content losses, and are expected to have no accompanying property losses due to flame damage. The news account mentions no fire extension into manufacturing plant nor injuries which resulted in an estimated $10,000 damage to dust collection bag house. Since dust collectors are constructed of metal they would be non-combustible.

In the U.S. Fire Administration/National Fire Data Center, Investigation of Confined Structure Fires, Topical Fire Research Series, the report noted 2002 NFIRS 5.0 data contain abbreviated reporting for slightly over 52,000 confined structure fire incidents—37% of structure fires.These incidents accounted for $26 million in combined losses, 3 deaths, and nearly 500 injuries. Most confined structure fires (77.5%) occurred on residential properties. It is the other 23% that we are concerned about in manufacturing non-residential properties.

There is a problem in this US Fire Administration reporting in that it does not formally consider dust collectors or other process equipment in the manufacturing sector that are non-combustible as confined structure fires. Instead, cooking fires, trash or rubbish fires, chimney fires, commercial compactor, fuel burners, and incinerators are used as data element descriptors in these type of fires.

This does present a problem since fire service professionals can't identify combustible dust fire hazards in the NFIRS 5.0 reporting system, then how can they assist stakeholders in evaluating and controlling combustible dust fire hazards. All combustible dust related fires are failed catastrophic combustible dust explosions. Time is way overdue for the FEMA/US Fire Administration's National Fire Data Center to review their fire reporting methodology that omits the dozens of minor combustible dust related fires that have a history of evolving into catastrophic dust explosions.

Combustible Dust Explosion Pharmaceutical Preparation Plant

A combustible dust explosion occurred at a pharmaceutical preparation plant in Iowa prior to the end of the 2010 a few weeks ago. Luckily there were no injuries or fatalities and damage was minor according to the news account.

"There were no injuries. The explosion blew out doors on the building and dust collectors, with additional minor damage."
Eastern Iowa News Now

It appears the mention of doors blowing out in the dust collector might be referring to explosion ventilation panels. Being that the plant is involved in pharmaceutical preparation with a NAICS 325412, it is noted in the OSHA Combustible Dust NEP in Appendix D-1 as an Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires.

Over the past 12 months OSHA has been enforcing a myriad of regulations in addition to ComDust NEP emphasis in their site visits at pharmaceutical preparation facilities. The OSHA Integrated Management Information System also referred to as IMIS provides a helpful insight to these inspections.

An educational General Duty Clause citation for one Pharmaceutical Preparation Plant noted that "neither dust collector was equipped with deflagration venting panels directed to an unoccupied area or with a suppression system. The collectors were located inside an occupied area which employees entered to conduct maintenance on a daily basis."This is in contrast to the current incident where the dust collector was installed outside on the roof and appeared to have explosion vent panels.

Results of an internet search produced a MSDS for microcrystalline cellulose (MCC) Cellulose; flour cellulose which has combustible dust fire explosion hazards. For example in the Fire Fighting section it notes, "Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard. For Cellulose: Minimum ignition temperature, dust cloud: 410C. Minimum explosible concentration: 0.045 g/l." This is helpful information so stakeholders can take proper administrative, PPE, and engineering control measures.

On a side note, another combustible dust related fire and explosion originated from the same company that occurred nearly two weeks prior to above incident, yet paper dust was the process material at a different facility instead of microcrystalline cellulose (MCC) according to the news account.

“Something caused the paper dust to explode. We don’t know what it was,” Battalion Chief Rick Palmer of the Portage Fire Department said. Palmer said the fire department has been called to explosions at the plant in the past, most recently about eight months ago. Small fires can develop wherever the dust settles in the plant following such an explosion, he said. “We just chase little fires all over the place,”
Michigan Live.com

Stakeholders searching the OSHA Combustible Dust NEP will not find any paper industries that OSHA believes have More Frequent and/or High Consequence Combustible Dust Explosions/Fires or Potential for Combustible Dust Explosions/Fires. Don't know what the NAICS is for the facility that generated paper dust in the news account yet there is mention that the facility produces paper insulation. In either case whether or not a facility is listed in the OSHA ComDust NEP, if you generate ComDust then you need to identify, evaluate, and control the fire and explosion hazards.

Thursday, January 13, 2011

U.K Combustible Dust Fire with Metal Dust

The fire was on the mezzanine floor in a hopper containing metal dust"
www.miltonkeynes.co.uk

OSHA needs to look at DSEAR and ATEX and include ComDust in the universe of potentially explosive atmospheres in the rulemaking process, which also includes flammable liquids, gases, vapors, and mists. Can't continue like the present situation in the USA with ComDust as a separate entity. Until then, the US Fire Administration will continue to ignore the fire and explosion hazards of ComDust with deficient incident reporting in the National Fire Incident Reporting System NFIRS 5.0

 

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